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4 <br /> Black Mountain Sand Weld LLC <br /> 500 Main St. Suite 1200, Fort Worth,TX 76102 <br /> (817) 698-9901 <br /> DRMS with their calculations. Black Mountain is actively working with DRMS on these calculations and <br /> will come to an agreement on reclamation costs and subsequent bonding requirements as part of the <br /> technical application review. While DRMS may take the initial draft calculations provided in Exhibit L into <br /> consideration, DRMS conducts an independent calculation of reclamation costs based on information <br /> provided throughout the application process and using their knowledge of the industry, and does not <br /> rely on these draft calculations alone. <br /> • "Why does BMS consider the final grading plan confidential?They have already provided the estimated <br /> amount of material to be excavated and processed in Table D3.The public should be able to review the <br /> proposed final contours."—According to the Rule 1.3(3) of the Construction Materials Rules,An <br /> Operator may mark "CONFIDENTIAL"information supplied in a permit application disclosing the <br /> location,size, or nature of the deposit or depth and thickness of the deposit and thickness and type of <br /> overburden to be removed. By this description, both Table D3 and the proposed final contours are <br /> allowed to be marked confidential and as such are not available to the public since combined,they <br /> describe both the size and nature of the deposit and the recovery rate of such deposit. <br /> • "As flocculants,also described as inert surfactants, are being used on this site (Exhibit D, Page 2),will the <br /> residual contamination left by the flocculants in the waste sands be allowed to be used in the <br /> reclamation?As states on Page 19 of the application, BMS states the chemical degrades within 14 days. <br /> BMS should provide information on the flocculants uses, such as an SDS,and information to verify the <br /> chemical degrades as they claim.Additionally, BMS should provide information on what the flocculant <br /> degrades into.They should also address the potential for the degraded components in the waste sands <br /> to migrate through the two foot groundwater buffer and impact the groundwater table.This <br /> information should be provided to DRMS prior to issuance of the reclamation permit."—The only inert <br /> surfactant proposed for use at the site is a water-soluble polymer,which will assist in the separation of <br /> clay and feldspar from the sand materials. It is a food grade compound commonly used to remove <br /> impurities from water in multiple industries, including municipal drinking water facilities, and degrades <br /> within 14 days.An SDS for the material will be kept onsite as part of the Spill Prevention, Control,and <br /> Countermeasures (SPCC) Plan.An SPCC is a required safety document that provides details of best <br /> management practices to be used at the site at all times, protection measures to be employed against <br /> spills, and cleanup and notification procedures and standards in the case of an accidental spill. <br /> • "Recommend that BMS address heavy metals within the existing soil and sand on site.Will these <br /> naturally occurring metals be concentrated in the"fines"when washed from the sand during the <br /> processing? If so,will they exceed regulatory limits and then how will they be managed? BMS should <br /> perform leaching tests on the existing soil and again on the processed "fines" material to verify they will <br /> not leach into the groundwater.The metals listed in Table E3 should be analyzed under this requirement <br /> as it is expected these metals could appear in the groundwater."—Black Mountain has already <br /> conducted leaching tests on both sampled material and proposed backfill materials.Test results show <br /> water from those materials will not negatively impact groundwater quality.The constituent list provided <br /> in Table E3 is a standard State recommended list of constituents for groundwater sampling throughout <br /> Colorado and does not indicate a likelihood for those specific constituents to appear in the surrounding <br /> groundwater system. <br /> • "A two foot buffer of separation between the groundwater table and bottom of mine does not appear <br /> to be sufficient to contain and/or filter releases of petroleum from on-site vehicles nor releases from <br /> leaching metals from the concentrated fines.An increases separation distance would allow BMS <br />